Case Digest (G.R. No. 209180) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Rezor Juanillo Manzano, Jr., G.R. No. 217974, decided March 5, 2018, the accused-appellant, Rezor Juanillo Manzano, Jr., and his brother Resurrecion Juanillo Manzano were charged with murdering Lucio Silava on the night of March 19, 2010 in Barangay San Angel, Hamtic, Antique. Armed with knives, the brothers allegedly entered Silava’s well-lit store-kitchen, surprisingly stabbed him repeatedly, and fled. Silava’s wife, Victoria, testified she saw both assailants stab her husband, who ran bleeding but was chased and fatally wounded. The Regional Trial Court (RTC), Branch 12, San Jose, Antique, rendered a judgment on April 17, 2012, convicting Rezor of Murder under Article 248 of the Revised Penal Code with treachery and abuse of superior strength, denied his plea of self-defense and voluntary surrender, and sentenced him to reclusion perpetua plus indemnities. The Court of Appeals (CA), Twentieth Division, affirmed this decision on October 29, 2014 Case Digest (G.R. No. 209180) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charge and Trial
- On or about March 19, 2010 in Hamtic, Antique, Rezor Juanillo Manzano Jr. and his brother Resurrecion were charged via Information with murder under Art. 248 RPC, alleging treachery and abuse of superior strength. An inverted trial was agreed; Rezor pleaded self-defense, Resurrecion remained at large.
- At trial, the prosecution presented: eyewitness Victoria Silava; Dr. Ma. Eva D. Pacificador’s postmortem report (15 stab wounds, hypovolemic shock); photos of blood spatter; SPO2 Javier’s testimony on surrender. The defense relied on Rezor’s own testimony claiming Lucio Silava attacked with stones and knife, forcing Rezor to defend himself.
- Parties’ Versions and Evidence
- Defense: Lucio threw stones at Rezor’s house, struck his knee, grappled for a knife; Rezor “blacked out” and stabbed Lucio in self-defense; he later surrendered.
- Prosecution: Victoria invited both accused to buy cigarettes; they suddenly stabbed Lucio in a well-lighted store and chased him as he fled bleeding; Victoria’s positive identification; postmortem confirmed fatal wounds; scene photos corroborated her account.
Issues:
- Whether the RTC erred in crediting Victoria Silava’s testimony despite alleged inconsistencies.
- Whether the RTC should have treated incomplete self‐defense as a mitigating circumstance.
- Whether abuse of superior strength was improperly found.
- Whether Rezor’s “voluntary surrender” warranted mitigation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)